Horizon scan: improvements to the UK transaction reporting regime?

The FCA is consulting on improvements to the UK transaction reporting regime under UK MiFIR, inviting feedback from market participants by 20 February 2026. This consultation follows client and industry input highlighting the complexities and inefficiencies in the current reporting framework across various regulations, including UK EMIR and UK SFTR.

Background: the FCA recognises that certain reporting regimes are duplicative and are disproportionate
Developments: the FCA will not completely overhaul the existing regime, but will focus on targeted alignment between overlapping reporting regimes
Derivatives carve-out: the FCA proposes exempting FX derivatives from reporting under UK MiFIR
Future directions and equivalent EU consultations
How Travers Smith can help

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Background: the FCA recognises that certain reporting regimes are duplicative and are disproportionate

Feedback to the FCA’s November 2024 discussion paper indicated that certain transactions face duplicated reporting requirements across UK MiFIR, UK EMIR, and UK SFTR. Many firms have been required to submit the same transaction data multiple times in varying data fields to different regulators. The FCA has acknowledged that this overlap has led to disproportionate compliance costs and operational burdens relative to the regulatory utility gained.

November 2024

FCA publishes a discussion paper seeking industry feedback on simplifying UK MiFIR reporting obligations, the scope of covered firms and instruments, and streamlining reportable data.
November 2025

FCA releases CP 25/32, proposing targeted improvements to the UK MiFIR transaction reporting regime.
20 February 2026

Deadline for submission of comments on CP 25/32.

Developments: the FCA will not completely overhaul the existing regime, but will focus on targeted alignment between overlapping reporting regimes

In its consultation, the FCA notes that it considered, but ultimately rejected, a single-template unified reporting regime to replace the current structure. The FCA concluded that the expense and disruption involved in a wholesale restructuring of reporting processes would outweigh potential benefits.

Instead, the FCA is focusing on aligning specific aspects of the reporting regimes, such as the names and definitions of data fields, guidance, and validation rules. This targeted approach aims to increase uniformity and reduce complexity where UK MiFIR overlaps or diverges from UK EMIR and UK SFTR.

Derivatives carve-out: the FCA proposes exempting FX derivatives from reporting under UK MiFIR

The FCA is proposing to remove FX derivatives from the scope of UK MiFIR reporting. It recognises that the current UK MiFIR data fields do not adequately capture the information needed to detect market abuse, but enhancing the fields would ultimately duplicate data already provided through UK EMIR. The FCA acknowledges that this change may give rise to more ad hoc requests for information when monitoring FX derivatives market abuse.

Future directions and equivalent EU consultations

In deciding not to address holistic duplication of reporting across the different regimes, the FCA has recognised the limitations of incremental changes. The FCA is partnering with HM Treasury and the Bank of England to develop a longer-term, cross-regime approach for transaction reporting.

Similar reforms are underway at the European Securities and Markets Authority, which consulted on the equivalent requirements in the EU in June 2025.

How Travers Smith can help

We have extensive experience advising clients on the broader UK and EU transaction reporting regimes and have been assisting various industry associations with their advocacy of alternative policy solutions for the UK framework.

For more information, please contact Jonathan Gilmour, Peter Hughes, or Elinor Samuel, or your usual Travers Smith contact.

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